Study guide

(1) BMW has not sent a response to our Request for Production of document- and the answers are

past due! Ms. Kirkland has asked you to draft a letter (for her signature), via Federal Express, to

Edwin Miller, attorney for BMW, asking them to send the documents. It's important that we

review them prior to the Discovery Conference set for July 10th of this year. If we don't get the

Answers to our Document Requests before then, we will have to file a Motion to Compel.

(2) You are working on a divorce case. Your firm represents the wife, Tiffani Martinez. You need to

send her the Alimony Plan that all parties agreed to at the last meeting. You need her to read,

sign, notarize, and return to you within two weeks. Draft the letter.

(3) Draft of settlement demand letter on behalf of your client, Stan Zippin, to Ed Miller, attorney for

BMW. You can make up necessary information (such as addresses, the amount of the demand,

etc).

(4) You have learned that Monte Mitchell is the CEO of Sprint. Ms. Kirkland would like to depose

Mr. Mitchell in our office. We would set up a court reporter. Write email to Sprint's attorney,

Mike Kayfield, asking for some upcoming days and times when Mr. Mitchell will be available for

a deposition. You also want to loop in the attorney for BMW, Ed Miller.